Superfund Program Proposed Plan Ellis Property Superfund Site · The Ellis Property site is located at 150 Sharp Road in Evesham Township, Burlington County, New Jersey. This property

Superfund Program Proposed Plan

Ellis Property Superfund Site Evesham Township, Burlington County, New Jersey

July 2013

Page 1

EPA ANNOUNCES PROPOSED PLAN

This Proposed Plan identifies the U.S. Environmental

Protection Agency’s (EPA’s) proposed change to the

soil and groundwater remedy selected in the September

30, 1992, Record of Decision (ROD) for the Ellis

Property Superfund site, located in Evesham Township,

New Jersey.

The original ROD in 1992 addressed soil and

groundwater contamination at the site. EPA, with the

concurrence of the New Jersey Department of

Environmental Protection (NJDEP), selected excavation

and off-site disposal of contaminated soils, and

construction of a groundwater collection and treatment

system to restore the contaminated groundwater as the

remedy for volatile organic compound (VOC)

contamination in groundwater at the site. The soil

component of the remedy is complete and the

groundwater collection and treatment system has been in

operation since 2000. However, as described below,

EPA and NJDEP have identified a source of VOC

contamination in the subsurface soils at the site. These

VOCs are contributing to groundwater contamination

and are preventing the groundwater collection and

treatment system from restoring the aquifer.

The groundwater remedy in the original ROD included

extraction and treatment of contaminated groundwater,

and reinjection of the treated groundwater upgradient

from the site. Performance monitoring of the

groundwater remedy indicates that it has only been

partially effective, and recent investigations reveal

additional contamination at the site: the presence of

residual sources (Residual Source Area) and an area of

contaminated soil (Plume Area). As a result, the goal of

the remedy for groundwater, aquifer restoration, cannot

be achieved within a reasonable time frame using the

existing system.

EPA’s preferred remedy to address the additional

contamination is excavation and off-site disposal of the

Residual Source Area and contaminated soil in the

Plume Area. EPA believes that it will take

approximately one year to excavate the source and

contaminated soil, followed by several years of

monitoring to confirm the effective remediation of the

groundwater plume.

This Proposed Plan includes summaries of the cleanup

alternatives evaluated for use at the site. This document

is issued by EPA, the support agency for site activities,

in conjunction with NJDEP, the lead agency for this site.

EPA is issuing this Proposed Plan as part of its public

participation responsibilities under Section 117(a) of the

Comprehensive Environmental Response,

MARK YOUR CALENDAR

PUBLIC COMMENT PERIOD:

July 12, 2013– August 12, 2013 EPA will accept written comments on the Proposed

Plan during the public comment period

PUBLIC MEETING:

Wednesday, July 24, 2013 6:30 p.m. EPA and NJDEP will hold a public meeting to explain

the Proposed Plan and all of the alternatives presented

in the Focused Feasibility Study. Oral and written

comments will also be accepted at the meeting. The

meeting will be held at Evesham Township Municipal

Building, Municipal Courtroom, 984 Tuckerton Road,

Marlton, New Jersey.

For more information, review the Administrative

Record at the following locations:

Evesham Library EPA-Region 2

984 Tuckerton Road Superfund Records Center

Marlton, NJ 08053 290 Broadway, 18th

Floor

(856) 983-1444 New York, NY 10007-1866

Hours: Monday - Thursday (212) 637-4308

10:00 am – 8:30 pm; Hours: Monday - Friday

Friday 10:00 am – 5:00 pm 9:00 am to 5:00 pm

R2-0004080

Page 2

Compensation, and Liability Act of 1980, as amended

(CERCLA), and Section 300.435 (c)(2)(ii) of the

National Oil and Hazardous Substances Contingency

Plan. This Proposed Plan summarizes information that

can be found in greater detail in the June 2013 Focused

Feasibility Study (FFS) and other documents contained

in the Administrative Record file for this site. This

Proposed Plan is being provided to inform the public of

EPA's preferred alternative and to solicit public

comments pertaining to the preferred alternative.

Changes to the preferred alternative, or a change from

the preferred alternative to another alternative, may be

made if public comments or additional data indicate that

such a change will result in a more appropriate remedial

action. The final decision regarding the selected remedy

will be made after EPA has taken all public comments

into consideration. The public is encouraged to review

and comment on the preferred alternative considered by

EPA in this Proposed Plan.

SITE BACKGROUND

The Ellis Property site is located at 150 Sharp Road in

Evesham Township, Burlington County, New Jersey.

This property was originally used as a dairy farm, until

acquired by Irving Ellis in 1968. Following the property

acquisition, approximately four of the 36 acres were

used in drum reconditioning operations. Surficial spills

and discharges in association with drum reconditioning

and chemical storage are believed to have contributed to

the observed contamination of soil and groundwater at

the site with chlorinated solvents and metals. Operations

ceased in the late 1970s following a fire at the site.

In response to an anonymous tip, in September 1980,

NJDEP conducted an inspection of the site. During this

visit, numerous corroded and leaking drums were

observed, in addition to dead and stressed vegetation in

the vicinity of drum storage locations.

NJDEP directed the removal of over 100 drums and

visibly contaminated surface soils as part of a removal

action in 1983, and the site was placed on the National

Priorities List (NPL). NJDEP then initiated a remedial

investigation/feasibility study (RI/FS) to determine the

nature and extent of the release.

Investigations during the RI identified numerous buried

drums. EPA performed a second removal action in 1989

that excavated and disposed of an additional 218 drums

from the site.

The RI identified soils contaminated with metals,

polychlorinated byphenyls (PCBs), and bis(2-

ethylhexyl)phthalate, and groundwater contaminated

with VOCs, particularly tetrachloroethylene (PCE) and

trichloroethylene (TCE). NJDEP completed the RI/FS

for the site, and worked with EPA to issue a Record of

Decision (ROD) in 1992, requiring the excavation of

contaminated soil and installation of a groundwater

collection, treatment and discharge system. The goal of

the groundwater action was to restore the groundwater to

drinking water standards.

Enforcement

Irving and Reba Ellis settled with EPA and NJDEP via

Consent Decree in June 1997. No other viable

potentially responsible parties have been identified for

the site, and investigation and cleanup activities have

been paid for with Federal and State funds, with NJDEP

as the lead agency.

SITE CHARACTERISTICS and DESCRIPTION OF

PROPOSED CHANGES

Original Remedy

The elements of the remedy selected in the original ROD

included the following:

R2-0004081

Page 3

Excavation of contaminated soil and

treatment/disposal at an approved off-site

facility;

Extraction of contaminated groundwater from

the shallow aquifer underlying the site;

Treatment of the contaminated groundwater in a

facility to be constructed on site;

Disposal of the treated groundwater on the site

by reinjection; and

Implementation of an environmental monitoring

program to ensure the effectiveness of the

remedy.

All these actions have been implemented. The ROD

identified approximately 760 cubic yards of soils

contaminated with metals, polychlorinated biphenyls

(PCBs) and bis(2-ethylhexyl)phthalate that exceeded the

site cleanup goals. Site-specific, risk-based cleanup

goals were selected based upon an assumption of

eventual unrestricted site use. When the soil remedy

was implemented in 1998, nearly 1,400 cubic yards of

soil exceeding the site cleanup goals was excavated for

off-site disposal. All the soil excavations and drum

removals were performed above the water table, which

is, on average, five feet below ground surface (bgs).

In addition to the soil actions identified in the ROD, an

area of soil contaminated with PCE was discovered

during the design phase of the groundwater remedy, and

was excavated down to approximately 12 feet bgs in

2000.

The groundwater treatment system was completed in

2000 and is still in operation today. The system consists

of a trench installed near the eastern edge of the site with

two extraction points (MH-1 and MH-2), two other

extraction wells (PW-1 and PW-2), a treatment plant,

and a re-injection trench. Groundwater is pumped from

the extraction points and is then treated and discharged

to the wetlands to the east and downgradient of the

collection trench.

The treatment consists of solids settling by gravity,

coagulation/flocculation and co-precipitation for metals

removal, sludge dewatering, and VOC removal via air

stripping and carbon adsorption. The system was

designed to operate at approximately five gallons per

minute (5 gpm) with a peak flow of 15 gpm. Currently

the system functions at a maximum rate of

approximately 7 gpm (including system recirculation)

due to system flow-through limitations (e.g., the

abundant presence of solids) and re-injection rate

constraints (e.g., treated water cannot be discharged as

quickly as the system can extract/treat it).

In addition to the groundwater treatment system, a total

of 38 monitoring wells and 14 piezometers are currently

used in the monitoring of local groundwater flow and

contaminant migration. These wells are screened in

three distinct formations underlying the site at the

following intervals: 22 shallow wells in the

Hornerstown Formation, approximately 10 to 20 feet

bgs; six intermediate wells in the Navesink Formation

approximately 50 to 60 feet bgs; and 10 deep wells in

the Wenonah-Mount Laurel Formation approximately 90

to 100 feet bgs.

New Information

While the removal and remedial response actions taken

to date have eliminated drums and large areas of

contaminated soil, residual TCE in localized areas of the

site along the interface of the Hornerstown Formation

and Navesink Formation have been consistently

identified in site monitoring wells during groundwater

monitoring. TCE and other VOCs found in groundwater

today were not identified as soil contaminants at the time

of the ROD because they were not detected at significant

levels.

In 2006, EPA performed a Remediation System

Evaluation (RSE) of site operations. An RSE involves an

independent team of expert hydrogeologists and

engineers conducting a broad evaluation of remedy

performance. The recommendations are intended to help

the site team identify opportunities for improvements.

The September 2006 RSE report identified several

enhancements to improve the performance of the

selected response action. In addition, the ROD had

called for studies of the site to identify the presence of

dense nonaqueous phase liquids (DNAPLs), typically

VOCs that might act as continuing sources of

contamination to the groundwater. In 2007, NJDEP

conducted a Pre-Design Investigation (PDI) to further

R2-0004082

Page 4

delineate the residual source(s) and extent of

contamination in soil and groundwater, to evaluate the

presence of DNAPLs, and assess potential changes to

the groundwater remedy.

Summary Of PDI Results:

A stratigraphy investigation was conducted in

the vicinity of MW-2, MW-6, PW-1, and PW-2

(See Figure 2). Cone penetrometer technology

(CPT) tests confirmed the existence of a “sand

channel” that could act as a preferential pathway

for contamination. The sand stratum was

identified between one and 9 feet thick at the site

and increased in thickness moving east to west

from MW-6 to MW-8.

Source area delineation of chlorinated solvent

contamination was conducted using a Membrane

Interface Probe (MIP). The MIP results

suggested that a residual contamination source

appeared to be relatively shallow (approximately

10 feet bgs) around boring location P22 (see

Figure 3), while it moved deeper (20 feet bgs)

into the clay layer around boring locations P53

and P5.

Investigation of groundwater quality was

conducted along the sand channel and potential

contamination source areas through collection of

groundwater samples via direct push sampling

points installed adjacent to selected MIP

investigation locations. The PDI confirmed that

there was no contamination in the sand channel

prior to entering the extraction trench.

Groundwater analytical results indicated TCE to

be the primary contaminant of concern

remaining at the site and that the primary

residual source areas were in the vicinity of

boring location P22 and P53 and P56.

TCE was detected in the groundwater in the

residual source area up to 14,000,000 µg/L at

depths between 10 and 26 feet below ground

surface. This concentration is two orders of

magnitude higher than the highest groundwater

monitoring well sample results (15,500 µg/L)

since 2003. Additionally, extraction well PW-2

has shown consistently elevated TCE levels

above 15,000 µg/L in the last 2 years of

sampling.

Investigation along the suspected sand channel

and contamination source areas was conducted

through the collection of soil samples adjacent to

selected MIP investigation locations. TCE was

the only compound that exceeded NJDEP

criteria, but was typically present at

concentrations exceeding 1milligram per

kilogram (1 mg/kg).

Overall, the PDI investigation identified TCE, found

predominantly between 10 and 24 feet bgs, as the

primary remaining concern at the site, with more

elevated concentrations identified during the PDI than

historical groundwater results. The significant levels of

TCE in the groundwater indicates the existence of a

WHAT IS THE “CONTAMINANT OF

CONCERN”?

The 1992 ROD identified a number of COCs for soils

and groundwater. EPA and the NJDEP have

identified trichloroethylene (TCE) as the primary

contamination remaining on site that poses the

greatest potential risk to human health. By

addressing TCE, other groundwater contaminants

would also be addressed.

TCE has been detected in groundwater at

concentrations ranging from non-detectable to

14,000,000 micrograms per liter (µg/L). This level

was detected in the “residual source area” of the site.

TCE concentrations from recent groundwater

sampling events regularly exceed 10,000 µg/L.

TCE is a halogenated organic compound that is

historically used as a solvent and degreaser and was

used during past drum reconditioning activities

conducted at the site. Exposure to TCE has

potentially harmful health effects in humans,

including anemia, skin rashes, diabetes, liver

conditions, and urinary tract disorders. TCE is also

considered a probable carcinogen based on laboratory

studies.

R2-0004083

Page 5

DNAPL source, but such a source has not yet been

found. The DNAPL source material constitutes a

principal threat waste at the site. The influence of

pumping wells PW-1 and PW-2 in extracting subsurface

contamination bound in the tight soil matrix is limited.

Note that these two pumping wells are well placed

relative to the TCE source areas and pumping has been

ongoing for more than 10 years, yet they appear to have

made little progress toward addressing these sources.

The primary cause of persistent elevated levels of

groundwater contamination in portions of the site

appears to be residual deep soil contamination below the

water table. These contaminants, bound tightly in the

soils, leach slowly out of the soils, serving as a

continuing source of groundwater contamination that is

not easily addressed by the existing system.

Based on a review of the groundwater monitoring results

from November 1999 to October 2010, multiple residual

source areas of TCE contamination appear likely at the

site. The primary potential source area in the shallow

zone is in the vicinity of monitoring wells MW-2 and

MW-6, continuing downgradient to the extraction

trench, where relatively high TCE concentrations persist.

A statistical analysis of the TCE concentrations detected

at MW-2 and MW-6 was conducted for eight quarterly

sampling events performed between October 2003 and

September 2005. This analysis illustrated that TCE

levels had not decreased at either MW-2 or MW-6

during this time period. Additionally, extraction well

PW-2, which is located between MW-2 and MW-6,

exhibited varying concentrations, which were

persistently detected at elevated levels for TCE in 2013,

as high as 47,195 µg/L. Another potential source area,

based on previous investigations, is in the vicinity of

extraction well PW-1, which has had elevated

concentrations of TCE in the influent to the treatment

plant in 2009 and 2010, as high as 31,286 µg/L in 2013.

The RSE and PDI also identified several issues likely to

affect overall system performance, including the location

of extraction wells in low-permeability soil formations

and the presence of the sand channel on the northern part

of the site. The sand channel was believed to limit the

effectiveness of the northern portion of the collection

trench in adequately intercepting contamination. A

cutoff wall was installed in 2012 to isolate the

contaminated groundwater from the sand channel and

direct it, instead, to the collection trench. This wall was

also designed to be used as a shoring protection for

excavation in the vicinity of the plume area.

SUMMARY OF SITE RISKS

A Baseline Human Health Risk Assessment (BHHRA),

and Ecological Risk Assessment were prepared as part

of the RI/FS at the time of the 1992 ROD. The

conclusions and assumptions of these risk assessments

were most recently reassessed by EPA as part of a Five

Year Review for the site in September 2010. EPA

concluded that the current and future land use

assumptions for the site are still valid, with an

expectation of future unrestricted residential land use.

The basis for taking an action at the site derived,

primarily, from direct contact or groundwater exposure

to a future resident.

The soil remedial action called for in the 1992 ROD

removed soil contamination within approximately the

first 10 feet of site soils, alleviating the potential for

direct contact. The soil cleanup goals at the time of the

ROD were for the following contaminants of concern

(COCs), with the ROD criteria and NJDEP’s current

unrestricted use soil standards:

Table 1

Contaminant of Concern

(in mg/kg)

1992 ROD

Soil

Cleanup

Goal

Current New

Jersey

Residential Soil

Remediation

Standards

Arsenic 20 19

Lead 400 400

Polychlorinated biphenyls

(PCBs) 0.49 0.22

Chromium 945 (20)*

Bis(2-ethylhexyl) phthalate 49 35

*NJDEP does not have a cleanup standard for total chromium;

it has an interim guideline of 20 mg/kg for hexavalent

chromium.

TCE was not selected as a COC for direct contact in the

original ROD, and while contamination remains at

depth, the expected response action would remediate

TCE to levels below NJDEP’s promulgated remediation

goal for unrestricted use (7 mg/kg), so the original RAOs

for soil would not be affected by a change to the original

remedy.

R2-0004084

Page 6

A comparison of the current groundwater standards with

the standards used at the time of the remedy selection

indicate several changes, as shown in Table 2. None of

these changes alter the scope of the selected remedy, or

this Proposed Plan.

Table 2

Contaminant of Concern

(in µg/L)

Groundwater

Cleanup

Goal at Time

of 1992 ROD

Current New

Jersey

Groundwater

Standard

Antimony 20 6

Arsenic 8 3

Beryllium 20 1

Bis(2-ethylhexyl)phthalate 30 3

1,2-dichloroethylene 2 1

Methylene chloride 3

Nickel 100

Tetrachloroethylene (PCE) 1 0.4

Trichloroethylene (TCE) 1 1

1,1,2-trichloroethane 5 3

Vinyl chloride 0.08

Total chromium 100 70

Lead (total) 100 5

Zinc 5,000 2,000

The groundwater exposure assumptions made at the time

of the 1992 ROD are still valid. The vapor intrusion

pathway was not evaluated at the time of 1992 ROD;

however, it is an incomplete exposure pathway because

there are no receptors. A comparison of the maximum

TCE and PCE concentrations with groundwater values

provided in the OSWER Draft Guidance for Evaluating

the Vapor Intrusion to Indoor Air Pathway from

Groundwater and Soils (November 2002) was conducted

as part of the 2010 Five Year Review. The screening

values used in the draft guidance provide groundwater

levels associated with an indoor air concentration that

represents a cancer risk ranging from 1 x 10-4

and

1 x 10-6

or a noncancer hazard quotient of 1.

Concentrations higher than these screening values

indicate the potential for vapor intrusion. TCE and PCE

concentrations found in groundwater exceed the 1 x 10-4

vapor intrusion screening values of 5.3 µg/L and 110

µg/L, respectively. For this reason, construction of any

type of building within the area of contaminated

groundwater may create conditions for a future vapor

intrusion exposure if the groundwater is not remediated.

Previous soil testing at the site (during the RI and

remedial action) was for total chromium, not for

trivalent or the more hazardous hexavalent chromium.

Based on new toxicity information on hexavalent

chromium, the cleanup goal for this chemical has been

lowered significantly. EPA and NJDEP do not have a

residential risk-based screening level for total chromium;

however, EPA’s screening value for trivalent chromium

is 120,000 mg/kg and for hexavalent chromium is 0.29

mg/kg. It is plausible that past site operations resulted in

hexavalent chromium impacts at the site; however, the

highest soil concentration of total chromium was 493

mg/kg, and chromium was not a remedy driver either as

a consequence of the RI/FS testing or during the

subsequent remedial action for soils. It is highly

unlikely that chromium in the soil could remain when

other soil contaminants were remediated. Thus, the

direct-contact pathways for the COCs identified in the

1992 ROD have been addressed by the already-

implemented soil remedy; however, because some of the

current levels are more stringent, they will be used when

determining completeness of the remedy going forward.

Confirmation sampling will be performed during the

cleanup.

The 2010 Five-Year Review also evaluated ecological

risks and concluded that while there have been changes

in how risk is calculated since originally assessed in

1992, the clean-up levels used for the upland portion of

the site appear to be protective of terrestrial receptors.

There are concentrations of TCE in the surface water,

but the concentrations are below chronic aquatic values.

Therefore, there are no surface water contaminants of

ecological concern.

REMEDIAL ACTION OBJECTIVES

Remedial action objectives are specific goals to protect

human health and the environment. These objectives are

based on available information and standards, such as

applicable or relevant and appropriate requirements

(ARARs) and risk-based levels established in the

BHHRA, prepared for the RI/FS at the time of the 1992

ROD. Because the BHHRA established that the soil and

groundwater at the site poses an unacceptable risk to

human health and the environment, remedial action

objectives (RAOs) were established in the 1992 ROD.

EPA and NJDEP have concluded that these remedial

action objectives are still appropriate. EPA has added

R2-0004085

Page 7

one additional RAO for groundwater, to address the

potential for vapor intrusion exposure.

Soil

Prevent contact with contaminated soil, which

represents an unacceptable risk, or reduce

contaminant concentrations in the soil below

risk-based levels;

Prevent further migration of soil contaminants

into the groundwater; and

Prevent migration of contaminated soils off site.

Groundwater

Prevent the migration of contaminated

groundwater off site;

Prevent the migration of contaminated

groundwater into the underlying aquifers;

Prevent potential exposure by inhalation/vapor

intrusion that presents unacceptable risk under a

future land use scenario; and

Return the aquifer to its designated use as a

source of drinking water by reducing

contaminant concentrations in the shallow

groundwater to drinking water quality.

It should be noted that the applicable New Jersey

drinking water and groundwater quality standard for the

primary contaminant of concern, TCE, of 1 µg/L has not

changed since the 1992 ROD. Based upon the 2007

PDI, the implemented remedy has only been partly

successful in achieving the RAOs for groundwater. The

results of the 2007 PDI identified the following

additional areas (not known at the time of the ROD) that

need to be addressed to meet the RAOs:

Residual Source Area: The horizontal extent of

TCE concentration s exceeding 11,000 µg/L,

representing likely DNAPL source material.

This area covers approximately 24,000 square

feet of the site. This area is typically found

between 10 and 24 feet bgs and is estimated at

approximately 22,500 cubic yards in volume.

Plume Area: The area outside of the Residual

Source Area that represents the horizontal extent

of TCE concentration greater than 100 µg/L.

This area covers approximately 61,000 square

feet of the site. This area is typically found

between 10 and 20 feet bgs and is estimated at

approximately 45,000 cubic yards in volume.

Full Area: This area covers approximately

85,000 square feet of the site, and is the sum of

the Residual Source Area plus the Plume Area

(67,500 cubic yards).

Please refer to Figure 2 showing Residual Source Area

in dotted line and the Plume Area in shade. The Full

Area consists of the Residual Area and the Plume Area.

The Residual Source Area and Plume Area were

considered separately because, while the same remedial

technologies could be implemented in either area, certain

technologies are more effective for higher concentration

areas and others more appropriate, from a cost and

effectiveness standpoint, for lower concentration areas.

Within these designated areas the soil remediation goal

for TCE will be 1 mg/kg, which is expected to achieve

the 1 µg/L remediation goal in groundwater.

SUMMARY OF REMEDIAL ALTERNATIVES

Technologies were screened in the Focused Feasibility

Study (FFS) to select a set of remedial technologies

appropriate for this site. The following five remedial

technologies were retained for further evaluation:

Excavation with Off-Site Disposal;

Enhanced Bioremediation;

In-Situ Chemical Reduction;

In-Situ Chemical Oxidation; and,

In-Situ Thermal Treatment

These retained remedial technologies were then used to

develop Remedial Alternatives to address contamination

and achieve RAOs at the site. These Alternatives

consisted of either individual or a combination of the

retained remedial technologies in order to best achieve

the remediation goals. The following Remedial

Alternatives were evaluated against all of the technology

screening criteria. The FFS considered two distinct in-

situ chemical treatment methods separately, but they

have been combined (e.g., Alternative 3 and Alternative

4 are now Alternative 3/4) for the Proposed Plan:

Alternative 1: Continuation of the Existing

Pump-and-Treat (P&T) System;

R2-0004086

Page 8

Alternative 2: Full Area Excavation with Off-

Site Disposal;

Alternative 3/4: Full Area In-Situ Chemical

Treatment;

Alternative 5/6: Residual Source Area

Excavation with Off-Site Disposal and Plume

Area In-Situ Chemical Treatment;

Alternative 7/8: Residual Source Area In-Situ

Chemical Treatment via Soil Mixing and Plume

Area Enhanced Bioremediation; and,

Alternative 9: Full Area In-Situ Thermal

Treatment

PROPOSED REMEDIAL ALTERNATIVES

Common Elements

Each of the remedial alternatives discussed below would

continue the institutional controls that currently prevent

use of the contaminated groundwater—a component of

the 1992 remedy. The institutional control for

groundwater is in the form of a classification exception

area (CEA). These controls need to be in place until the

aquifer is restored. In addition, until the RAO of aquifer

restoration is achieved, each alternative would require

engineering controls for vapor mitigation (vapor

barriers, vapor mitigation systems and/or monitoring), if

buildings come to be placed over any of the groundwater

contamination zones identified for the site.

With the exception of Alternative 1, Continuation of the

Existing P&T System, each of the other alternatives is

designed to treat TCE as the main risk driver.

During the implementation phase of the alternatives, the

existing P&T system would remain in place and

operational, preventing further contaminant migration.

After completion of the remedial actions devised for

each alternative, the groundwater P&T system would

remain in place for some period while the aquifer

recovered. The anticipated length for this stage of each

alternative varies, as discussed below.

Alternative 1: Continuation of the Existing P&T

System

Capital Cost – Not Applicable (N/A)

Total Cost – $ 10,000,000

Implementation Period – N/A

This remedial alternative assumes that no new actions

will be implemented at the site and the existing P&T

system will continue to operate for a minimum of 30

years. For costing purposes, 30 years is assumed;

however, the operation period of 30 years is considered

to be indefinite considering the limited effectiveness of

the system since operation began in 2000, and the period

required to reach the RAOs may be substantially longer

than 30 years. Annual groundwater monitoring would

be conducted for approximately 30 years to track

performance of the remediation.

Alternative 2: Full Area Excavation with Off-Site

Disposal

Capital Cost – $10,518,000

$783,000

Total Present Worth – $13,600,000

Implementation Period – 1 year

This remedial alternative involves excavation and off-

site disposal of contaminated soil in the Full Area, which

comprises the residual source area and the plume area.

This alternative would provide the removal of the

residual source area and contaminated soil in the plume

area, reduce contamination concentrations across the site

and result in a significantly shorter operation period for

the P&T system.

Contaminated soils would be excavated from an average

depth interval of 10 to 20 feet bgs, and as deep as 30 feet

bgs in some limited areas. Approximately 67,500 cubic

yards of soil would be excavated from the site. The

upper soils (approximately 31,500 cubic yards) from

zero to 10 feet bgs that are not contaminated would be

excavated and stockpiled and used for backfill.

Contaminated soils would be disposed as hazardous

waste at an RCRA-approved off-site disposal facility.

Dewatering would be necessary during the excavation of

the saturated portion of the soil.

Additional excavation may be conducted in some select

areas based on field screening and observation during

the excavation activities. Approximately 15 new

monitoring wells would be installed to replace the

existing wells that would be abandoned prior to the

excavation activities. Operation of the existing

groundwater P&T system would be continued during the

R2-0004087

Page 9

excavation; the system would be limited to extracting

groundwater from collection trench only, because the

extraction wells PW-1 and PW-2 are in the excavation

area and would be abandoned prior to the excavation

activities.

Groundwater levels are expected to reach the

remediation goals within a relatively short period after

completion of the soil excavation, without further

remedial activities; however, the P&T system would

remain in place after completion of the excavation to

evaluate the effectiveness of continued operation of this

system to further reduce the residual groundwater

contaminants. For the purpose of the FFS, the period of

operation for the P&T system was assumed to be one

year after completion of the remedial action; quarterly

groundwater monitoring was assumed to be conducted

for the first year, followed by annual groundwater

monitoring for the next nine years to monitor the

remedial performance. Actual period of operation of the

P&T system and groundwater monitoring schedule will

be determined by EPA after completion of the remedial

action and will be based on achieving the performance

standards set during design.

Alternative 3/4: Full Area In-Situ Chemical

Treatment

Capital Cost – $1,515,000- $2,185,000

Annual O&M $783,000

Total Cost – 2,800,000-$3,600,000

Implementation Period – 1 year

This alternative includes the use of in-situ chemical

treatment, either in-situ chemical reduction (ISCR)

[Alternative 3] or in-situ chemical oxidation (ISCO)

[Alternative 4] to remediate soil and groundwater

contamination at the site. Final selection of the in-situ

treatment technology would be made after further studies

in remedial design, and the site may require a

combination of different in-situ technologies to address

site contamination.

ISCR uses chemical reductants such as zero-valent iron

(ZVI). The ZVI donates electrons, acting as the

reductant in a reaction that removes chlorine atoms from

chlorinated hydrocarbon contaminants such as TCE.

The ZVI reaction is a rapid process and thus requires a

short time frame to reach remedial goals. The limiting

factor for the technology is the delivery of the ZVI into

the aquifer. It is anticipated that ZVI would be injected

through a total of approximately 100 locations based on

a 30-foot grid injection pattern. ZVI would be injected

in a slurry using direct-push technology to the target

depth interval of 10 to 30 feet bgs. It is assumed that two

injection events (assuming one to two months apart)

would be needed and a total of approximately 26,000

pounds of ZVI would be injected.

ISCO is a process that involves the injection of reactive

chemical oxidants (such as Peroxide, Fenton's Reagent,

Permanganate) into the subsurface for rapid contaminant

destruction. Oxidation of organic compounds using

ISCO is rapid and exothermic and results in the

reduction of contaminants to primarily carbon dioxide

and oxygen.

Modified Fenton’s Reagent was assumed to be the

oxidant, for costing purposes. Modified Fenton’s process

combines proprietary chelated iron complex catalysts,

mobility control agents, oxidizers, and stabilizers. The

process generates powerful free radicals when the

catalyst reacts with hydrogen peroxide to promote co-

existing oxidation-reduction (redox) conditions.

As with ISCR, ISCO is generally a rapid reaction, and

the technology is limited by the ability to deliver the

oxidant to the aquifer. It is anticipated that the Modified

Fenton’s Reagent would be injected through a total of

approximately 300 points based on a 16-foot grid

injection pattern using direct-push technology to the

target depth interval of 10 to 30 feet bgs. It is assumed

that 3 injection events (one to two months apart) would

be needed and a total of approximately 240,000 gallons

of the Modified Fenton’s Reagent would be injected.

Delivery of the selected chemical is critical to the

success of this technology. Due to the tightness of the

soil matrix, results of the PDI suggest that uniform

delivery of the selected chemical would be difficult.

In Alternative 3 or Alternative 4, the groundwater will

be monitored during treatment to prevent the migration

of reagents or free radicals.

R2-0004088

Page 10

The FFS assumes that groundwater would be extracted

from collection trench only and treated on site through

existing treatment system for one year to avoid: 1)

interference with the chemical treatment in the target

treatment area; and 2) impact of chemical reducing

agents to the existing P&T system. Treated groundwater

would be discharged mostly to surface water, with a

portion being discharged via groundwater. For the

purpose of the FFS, quarterly groundwater monitoring

was assumed to be conducted for the first year, followed

by semi-annual groundwater monitoring for the next

nine years to monitor the remedial performance. Actual

period of operation of the P&T system and groundwater

monitoring schedule will be determined by EPA after

completion of the remedial action and will be based on

achieving the performance standards set during design.

Alternative 5/6: Residual Source Area Excavation

with Off-Site Disposal and Plume Area In-Situ

Chemical Treatment

Capital Cost – $6,371,000-$6,383,000

$783,000

$8,600,000

Implementation Period – 3 years

This remedial alternative combines the use of

Excavation with Off-Site Disposal (Alternative 2) to

address contamination in the Residual Source Area

followed by in-situ chemical treatment (either ISCR or

ISCO) to address contamination in the Plume Area.

Alternative 5 utilizes ISCR, while Alternative 6 utilizes

ISCO.

In the Residual Source Area, soils would be excavated as

described in Alternative 2 from approximately 10 to 20

feet bgs with the excavation as deep as 30 feet bgs in

some limited areas. Approximately 22,500 cubic yards

of soil would be excavated. After excavation,

contaminated soils would be disposed of at RCRA-

approved off-site disposal facilities.

In-situ chemical treatment would be then be used to

address the contamination in the Plume Area. If ISCR is

used (Alternative 5), a slurry of ZVI would be injected

through a total of approximately 70 locations based on a

30-foot grid injection pattern. ZVI would be injected in a

slurry using direct-push technology. It is assumed that 2

injection events (assuming one to two months apart)

would be needed and a total of approximately 12,000

pounds of ZVI would be injected.

ISCO is considered more implementable than ISCR, as

the exposure of ZVI to air during the mixing process

would reduce its effectiveness. If ISCO is used

(Alternative 6), Modified Fenton’s Reagent would be

used to address the contamination in the Plume Area.

The oxidant would be injected through a total of

approximately 240 points based on a 16-foot grid

injection pattern using direct-push technology. It is

assumed that 3 injection events (assuming 1 to 2 months

apart) would be needed and a total of approximately

144,000 gallons of the Modified Fenton’s Reagent

would be injected.




After completion of the Plume Area remedial action,

operation of the existing groundwater P&T system was

assumed to operate one year, extracting groundwater

only from collection trench, because the extraction wells

will be abandoned and removed during the excavation

activities. For the purpose of the FFS, quarterly

groundwater monitoring was assumed to be conducted

for the first year, followed by semi-annual groundwater





action and will be based on achieving the performance


Alternative 7/8: Residual Source Area In-Situ

Chemical Treatment via Soil Mixing and Plume Area

Enhanced Bioremediation

Capital Cost – $2,858,000-$3,298,000

$872,000

$4,600,000-5,100,000


This remedial alternative involves the use of in-situ

chemical treatment, with in-situ soil mixing (rather than

chemical injection used in Alternatives 3/4 and 5/6), to

address contamination in the Residual Source Area,

R2-0004089

Page 11

followed by the use of enhanced bioremediation to

address contamination in the Plume Area.

High TCE concentrations in the Residual Source Area

would be addressed by in-situ chemical treatment (as

described in Alternative 3/4). Alternative 7 utilizes

ISCR, while Alternative 8 utilizes ISCO. Treatment

chemicals would be applied in the Residual Source Area

using an in-situ soil mixing method. Prior to the soil

mixing, steel sheet piles will be installed to an

approximate depth of 40 feet bgs to support stability of

soil in the mixing area. The uncontaminated upper soil,

from zero to 10 feet bgs (approximately 9,000 cubic

yards) would be excavated and stockpiled. Treatment

chemicals (approximately 11,200 pounds of ZVI or

144,000 gallons of Modified Fenton’s Reagent) would

be mixed with contaminated soils using an excavator.

Target depth zones for in-situ mixing of contaminated

soils are from 10 to 20 feet bgs, with mixing as deep as

30 feet bgs in some limited areas. After the soil mixing

is complete, the excavation area would be backfilled

with the stockpiled soils.

Approximately five new monitoring wells would be

installed to replace the existing wells abandoned and

removed prior to the excavation and soil mixing

activities.

Enhanced bioremediation would then be used to address

the contamination in the Plume Area. The following

description assumes that an edible oil substrate (EOS)

would be used as the reducing agent for the treatment,

though other means are used to augment biodegradation

within the aquifer.

It is anticipated that the EOS would be injected at a total

of approximately 150 locations based on a 20-foot grid

injection pattern using direct-push technology.

Depending on the ability of intrinsic microorganisms to

completely reduce site contaminants, bioaugmentation

(adding microorganisms to the aquifer) may also be used

to stimulate complete reductive dechlorination of TCE’s

breakdown products (dichloroethylene and vinyl

chloride) to ethane. The FFS assumed that one

application of EOS would be required to address TCE

concentrations in the Plume Area.




The combined remedial action is expected to take

approximately five years to complete. Operation of the

existing groundwater P&T system was assumed to be

continued for one additional year. The system would be

limited to extracting groundwater from collection trench

only and on-site treatment through existing treatment

system to avoid: 1) interference with the chemical

reduction in the target treatment area; and 2) impact of

chemical reducing agents to the existing P&T system.

For the purpose of the FFS, quarterly groundwater

monitoring was assumed to be conducted for the first

three years, followed by semi-annual groundwater





action and bill be based on achieving the performance


Alternative 9: Full Area In-Situ Thermal Treatment

$4,504,000

$783,000

Total Cost – $6,400,000


Thermal Treatment is an in-situ physical treatment via

subsurface heating to enhance the volatilization and

subsequent capture and treatment of VOCs. Heating can

be achieved via several options, including electrical-

resistance heating (i.e., passing electricity through soil

via electrodes), steam injection, and thermal conduction

(via electrical heaters).

The FFS assumed electrical resistance heating (ERH) as

the treatment method for this alternative. ERH is an in-

situ thermal technology that passes electrical current

among electrodes placed in the subsurface. Electrical

resistance generates heat that eventually causes water in

the subsurface to gently boil. Steam stripping,

volatilization and other mechanisms, such as hydrolysis

and increased chemical reaction rates, rapidly remediate

subsurface contaminants.

R2-0004090

Page 12

Approximately 200 electrodes would be installed to 30

feet bgs over the approximately 80,000 square feet of the

Full Area. A total of 200 vapor recovery wells and 25

temperature monitoring points would also be installed.

Operation of the existing groundwater P&T system was

assumed to continue for one year, extracting

groundwater from collection trench only, because the

extraction wells PW-1 and PW-2 would need to be

abandoned and removed prior to the installation

activities for the thermal treatment system.

It is estimated that total heating treatment would be

conducted over an eight to 10-month period and vapor

and groundwater samples would be collected

periodically to monitor system performance. For the

purpose of the FFS, groundwater monitoring would be

conducted for the first year, followed by semi-annual

groundwater monitoring for the next nine years to

monitor the remedial performance. Actual period of

operation of the P&T system and groundwater

monitoring schedule will be determined by EPA after

completion of the remedial action and will be based on

achieving the performance standards set during design.

EVALUATION OF REMEDIAL ALTERNATIVES

Nine criteria are used to evaluate the different

remediation alternatives individually and against each

other in order to select a remedy, (see table on following

page, “Evaluation Criteria for Superfund Remedial

Alternatives”). This section of the Proposed Plan

profiles the relative performance of each alternative

against the nine criteria, noting how each compares to

the other options under consideration. A detailed

analysis of alternatives can be found in the FFS.

Evaluation Criteria

Each remedial alternative was screened using the

following evaluation criteria to determine which

alternative will be most effective in achieving the RAOs:

Overall Protection of Human Health and the

Environment

Alternative 1 (Continuation of the Existing P&T

System) would not protect human health or the

environment because it would not address the residual

soil and groundwater contamination. All of the other

alternatives would provide protection of human health

and the environment by addressing the residual soil and

groundwater contamination remaining at the site,

coupled with engineering controls (including vapor

mitigation, if needed, in the future), and institutional

controls.

Compliance with ARARs

While groundwater is not currently in use, applicable

drinking water standards are exceeded throughout the

site for TCE and a few other constituents. TCE levels at

the site exceed the New Jersey Groundwater Quality

Standards for a Class IIA aquifer. A CEA is in place to

prevent use of groundwater while it remains

contaminated, and this CEA would remain in place for

any of the remedial alternatives considered.

All of the remedial alternatives discussed for

remediation of soil and groundwater contamination

would meet their respective ARARs and are consistent

with all applicable Federal, State, and local laws and

regulations, in particular, the relevant parts of the New

Jersey Technical Requirements for Site Remediation

(N.J.A.C. 7:26E).

All of the remedial alternatives would meet the NJDEP

soil cleanup standard for unrestricted use for TCE of 7

mg/kg. In addition, the active remedial alternatives are

expected to achieve an Impact-to-Groundwater

remediation goal of 1 mg/kg, which EPA has developed

for TCE at similar sites using NJDEP’s Impact to

Groundwater Soil Screening guidance. While not an

ARAR, this guidance is “To-Be-Considered” criteria.

RCRA land-disposal requirements would govern the

disposition of excavated material designated for off-site

disposal.

No other major ARARs considerations affect remedial

decision-making. All the Alternatives would be

completed in compliance with chemical-, action- and

location-specific ARARs.

Long-term Effectiveness and Permanence

All of the remedial alternatives are capable of removing,

reducing, and/or mitigating the site contaminants.

R2-0004091

Page 13

Alternatives 2 (Full Area Excavation with Off-Site

Disposal) and 9 (Full Area In-Situ Thermal Treatment)

are considered to be effective over the long term because

the technologies are more suitable for addressing

contamination situated in the tight geological conditions

present at the site.

The tight geologic formation, which has limited the

effectiveness of the current remedy to extract

contaminants from the subsurface, is expected to cause

problems for some of the in-situ treatment technologies

(Alternatives 3/4 and 5/6) during injection of reagents

and chemicals to the contamination zones. Alternative

7/8 (Residual Source Area In-Situ Chemical Treatment

via Soil Mixing and Plume Area Enhanced

Bioremediation) is more effective and reliable because

high contaminant concentrations in the Residual Source

Area would be effectively reached and degraded by

chemical reduction or chemical oxidation using soil

mixing. Also, the enhanced bioremediation technology

introduces chemical amendments into the areas to be

treated that stay active for several months, and this

extended contact time may overcome the low

permeability of the soil formation; thus it may be more

effective at addressing low concentrations in the Plume

Area.

Alternative 5/6 (Residual Source Area Excavation with

Off-Site Disposal and Plume Area In-situ Chemical

Treatment) is deemed to be the next most effective and

permanent alternative over the long term. Soil

excavation would effectively remove contaminants in

the Residual Source Area. However, in-situ chemical

treatments tend to involve quick-acting chemicals

(relative to the slower degradation processes involved in

enhanced bioremedation), that do not stay active in the

ground for more than a few days. Small portions of the

relatively low contaminant concentrations in the Plume

Area may be untreated due to the tight formation that

prevents quick contact with the treatment agents.

Multiple treatments may be required to effectively treat

these areas. Alternative 3/4 calls for the same in-situ

chemical treatment, but throughout the whole treatment

zone. It is expected, along with Alternative 1

(Continuation of the Existing P&T System) to have the

most difficulty with effectiveness over the long term,

due to untreated residues not reached by the remedial

action and the difficulty of treating DNAPLs.


System) would be the least effective over the long term.

Results from samples collected from monitoring wells

and soil sampling locations indicate that the groundwater

extraction system has not effectively extracted

contaminant from the aquifer or reducing groundwater

contamination.

EVALUATION CRITERIA FOR SUPERFUND REMEDIAL

ALTERNATIVES

Overall Protectiveness of Human Health and the Environment evaluates

whether and how an alternative eliminates, reduces, or controls threats to

public health and the environment through institutional controls, engineering

controls, or treatment.

Compliance with ARARs evaluates whether the alternative meets federal and

state environmental statutes, regulations, and other requirements that are

legally applicable, or relevant and appropriate to the site, or whether a waiver

is justified.

Long-term Effectiveness and Permanence considers the ability of an

alternative to maintain protection of human health and the environment over

time.

Reduction of Toxicity, Mobility, or Volume of Contaminants through

Treatment evaluates an alternative's use of treatment to reduce the harmful

effects of principal contaminants, their ability to move in the environment,

and the amount of contamination present.

Short-term Effectiveness considers the length of time needed to implement

an alternative and the risks the alternative poses to workers, the community,

and the environment during implementation.

Implementability considers the technical and administrative feasibility of

implementing the alternative, including factors such as the relative

availability of goods and services.

Cost includes estimated capital and annual operations and maintenance costs,

as well as present worth cost. Present worth cost is the total cost of an

alternative over time in terms of today's dollar value. Cost estimates are

expected to be accurate within a range of +50 to -30 percent.

State/Support Agency Acceptance considers whether the State agrees with

the EPA's analyses and recommendations, as described in the RI/FS and

Proposed Plan.

Community Acceptance considers whether the local community agrees with

EPA's analyses and preferred alternative. Comments received on the

Proposed Plan are an important indicator of community acceptance.

R2-0004092

Page 14

Reduction of Toxicity, Mobility, or Volume of

Contaminants through Treatment

Alternatives 3/4, 5/6, 7/8, and 9 satisfy CERCLA’s

preference for remedies that use treatment to reduce the

contaminant mass.


System) has not demonstrated a capacity to reduce the

toxicity, mobility or volume of the Residual Source

Areas within tight soil matrix at the site.

Alternative 2 (Full Area Excavation with Off-Site

Disposal) removes the residual source and contaminated

material from the site, and while some of the excavated

material may require treatment before it can be land-

disposed, therefore it satisfies EPA’s preference for

remedies that use treatment as a principal element.

Short-term Effectiveness

All of the proposed remedial alternatives except for


System) are expected to reduce TCE contamination and

achieve the RAOs within approximately five years,

which is considered a relatively short duration.

Alternative 2 will reduce TCE contamination in the

shortest time, with the most certainty. Alternatives 3/4

and 9 are expected to reduce TCE contamination in a

short amount of time (between one and two years).

However, there is higher uncertainty that these

technologies will be effective in this aquifer. Alternative

5/6 is expected to reduce contamination within three

years. Alternative 7/8 is expected to reduce TCE

contamination in about five years.

None of the remedial technologies pose insurmountable

short-term risks. All the alternatives pose short-term

health risks to workers that need to handle hazardous

substances and work at a large-scale construction

project, and these risks will need to be properly managed

through worker health and safety programs. These

programs are standard practice at all Superfund sites, as

are health and safety measures to assure that no

exposures to nearby properties occur during remedial

actions.

Soil excavation in Alternatives 2, and 5/ 6 would also

create the most additional truck traffic, a disruption for

the nearby community. All the alternatives (with the

exception of Alternative 1) will increase truck traffic, but

Alternative 2 would generate more than twice the

number of trucks on the road to the next nearest

Alternative (Alternative 5/6, which also calls for

extensive excavation and off-site disposal). EPA would

need to work with the community to mitigate the traffic

impacts as much as possible.

Although unlikely, Alternative 9 (Thermal Treatment)

could potentially cause uncontrolled migration of

contaminants vaporized by the thermal heating and not

captured by the vapor extraction/recovery system. The

installation and operations of the electrical system

involved with the Thermal Treatment may also present

significant physical hazards and would also require

specific safety precautions and training.

Remedial technologies in Alternatives 3/4, 5/6 and 7/8

pose some minor short-term health risks to workers

during the injection activities. Alternative 1

(Continuation of the Existing P&T System) poses the

least short-term health risks to workers.

Implementability

The materials, system components, skills and labors are

readily available for all of the technologies and remedial

alternatives proposed. Therefore, all alternatives are

considered implementable. However, Alternative 9 (Full

Area In-Situ Thermal Treatment) is more difficult to

implement due to the considerable system installation,

startup and operations, including drilling, wells

installation, and mechanical, electrical, and vapor

extraction and treatment systems.

Alternative 2 (Full Area Excavation with Off-Site

Disposal) would require a considerable amount of

planning, heavy equipment, structural support (through

steel sheet piles, etc.), staging areas, and overall

coordination of the excavation activities to depths of 20

feet bgs, with 30 feet bgs in some limited areas.

However, these deeper excavations require no

specialized equipment and are typical in standard

construction practice. Alternatives involving Enhanced

Bioremediation, ISCR or ISCO (3/4, 5/6, and 7/8) would

require a considerable number of injection locations, but

all the injection points are on the property, and relatively

R2-0004093

Page 15

shallow, so not difficult to implement. These in-situ

response actions are also constrained by the ability to

effectively deliver the treatment reagents to the

subsurface soil and in addressing DNAPLs. For

Alternative 7/8, which requires soil mixing, ISCO is

considered more implementable than ISCR, as the

exposure of ZVI to air during the mixing process would

reduce its effectiveness.

The groundwater P&T system is already in place at the

Site. Although the system may require modification,

Alternative 1 is considered easy to implement.

Cost

The most cost-effective remedial alternatives are

Alternatives 3/4 (($2,800,000-$3,600,000), 7/8

(($4,600,000-$5,100,000), and Alternative 9

($6,4000,000); while Alternative 1 ($10,000,000) and

Alternative 2 ($13,600,000) are the least cost-effective.

State/Support Agency Acceptance

The State of New Jersey supports the preferred

alternative as presented in this Proposed Plan.

Community Acceptance

Community acceptance of the preferred alternative will

be evaluated after the public comment period ends and

will be described in the Record of Decision, the

document that formalizes the selection of the remedy for

the site.

SUMMARY OF THE PREFERRED ALTERNATIVE

The Preferred Alternative for the remediation of TCE

contamination at the Ellis Property Superfund site is

Remedial Alternative 2, which involves the use of

excavation and off-site disposal, to address

contamination in the Full Area.

The Preferred Alternative was selected over the other

remedial alternatives because it is expected to be

protective of both human health and the environment

while reducing/removing the residual source in a cost-

effective manner. The Preferred Alternative would

achieve the remediation goals for the principal threat

source areas and for soils. This Remedial Alternative

has been determined to be the most cost-effective and

protective of human health and the environment while

effectively addressing TCE contamination in a relatively

short period of time. This alternative is considered

readily implementable to overcome the existing site

conditions.

The Preferred Alternative was also determined to be

effective in achieving the RAOs and ARARs. The

potential presence of DNAPL in the Residual Source

Area, which is considered the continuing source of

groundwater contamination, was considered to be the

most difficult problem for the other technologies to

address effectively, particularly in comparison to

Alternative 2. The current groundwater collection

trenches and treatment system would remain in place

during the implementation of the preferred alternative

and for a short period thereafter, and natural

bioremediation processes are expected to restore the

aquifer to the cleanup goals within a period of

approximately one to three years. Overall, the

implementation of the Preferred Alternative is expected

to reduce the duration of the operation of the existing

P&T system to one year after the completion of remedial

activities. In addition, the Preferred Alternative is

expected to minimize the future migration of

groundwater contamination; reduce or eliminate the

source of future groundwater contamination; and, reduce

or eliminate the direct contact threat associated with

contaminated soil.

Based on the information currently available, EPA and

NJDEP believe the Preferred Alternative meets the

threshold criteria and provides the best balance of

tradeoffs among the other alternatives with respect to the

balancing and modifying criteria. EPA and NJDEP

expect the Preferred Alternative to satisfy the following

statutory requirements of CERCLA §121(b): (1) be

protective of human health and the environment; (2)

comply with ARARs (or justify a waiver); (3) be cost-

effective; (4) utilize permanent solutions and alternative

treatment technologies or resource recovery technologies

to the maximum extent practicable; and (5) satisfy the

preference for treatment as a principal element, or

explain why the preference for treatment will not be met.

R2-0004094

Page 16

COMMUNITY PARTICIPATION

EPA and NJDEP provide information regarding the

cleanup of the Ellis Property Superfund site to the public

through public meeting, the Administrative Record file

for the site, and announcements published in the local

newspaper. EPA and the NJDEP encourage the public

to gain a more comprehensive understanding of the site

and the Superfund activities that have been conducted at

the site.

For further information on the Ellis Property site please

contact:

Richard Ho

Remedial Project Manager

(212) 637-4372

[email protected]

Natalie Loney

Community Relations Coordinator

(212) 637-3639

[email protected]

Carlton Bergman

Site Manager

NJDEP

401 East State Street

Trenton, New Jersey 08625

Phone: (609) 633-6621

Written comments on this Proposed Plan should be

addressed and mailed to Mr. Ho at:

U.S. EPA Region 2

290 Broadway 19th

Floor

New York, New York 10007-1866

The public liaison for U.S. EPA Region 2 is:

George H. Zachos

Regional Public Liaison

Toll-free (888) 283-7626

(732) 321-6621

U.S. EPA Region 2

2890 Woodbridge Avenue, MS-211

Edison, New Jersey 08837-3679

R2-0004095

mailto:[email protected]




Page 17

Figure 2

R2-0004096

Page 18

Figure 3

R2-0004097

Superfund Program Proposed Plan Ellis Property Superfund Site · The Ellis Property site is located at 150 Sharp Road in Evesham Township, Burlington County, New Jersey. This property

Documents